BirdWatch Ireland welcomes changes to winter stubble rules
BirdWatch Ireland has welcomed scrapping the rule for shallow cultivation of winter stubbles in the latest review of the Nitrates Action Programme (NAP).
In a statement, BirdWatch Ireland said: "It is regrettable that this decision was not made sooner and before farmers cultivated stubble grounds in 2025, leaving threatened bird species looking for other food supplies this winter.
"In the medium and long-term Ireland’s Common Agriculture Policy (CAP) Strategic Plan and National Restoration Plan must incentivise farmers to provide sufficient quantity and quality of habitats to restore both wintering and breeding farmland bird populations."
The winter stubble rule was introduced in 2022, despite strong opposition at the time from BirdWatch Ireland due to the risk of severe impacts to farmland birds over the winter months when food supplies for many Red and Amber Listed Birds of Conservation Concern in Ireland are in short supply.
The stubble fields left after crops have been harvested contain spilled seeds, which seed-eating birds like the yellowhammer, as well as rodents, will eat during the cold winter.
These small birds and rodents are prey species for other birds, including the hen harrier, a highly protected and increasingly rare bird of prey that is experiencing ongoing declines.
BirdWatch Ireland
BirdWatch Ireland's submission to government highlighted that 30 Red or Amber Listed Birds of Conservation in Ireland relied on winter stubbles for food.
In addition, according to the wildlife organisation, nitrate pollution is a severe problem in Ireland and has to be addressed.
It said: "It is having well-documented consequences for our waterways and threatens riverine bird species like kingfisher, dipper, grey wagtail, and others.
"The shallow cultivation rule was introduced to address nitrate leaching from arable land but without assessment of the impacts to threatened bird species known to forage on stubbles.
"The Natura Impact Statement of the Nitrates Action Programme in 2022 did not assess the impacts of the shallow cultivation of stubbles rule on Annex 1 hen harrier and golden plover or any other protected species as is required under the Habitats Directive.
"We raised our concerns about this with government," Birdwatch Ireland said.
The organisation also highlighted that the shallow cultivation rule was also not in line with known ecological requirements for hen harrier, especially juvenile birds, in the Hen Harrier Threat Response Plan, also published by the government.
Winter stubble
According to BirdWatch Ireland, in 2022, the government assigned Teagasc the task of researching the impact of a reduction in winter stubble after the rule had been brought in. This research is ongoing.
A study undertaken in 2023 on 30 farms in an area of south Co. Cork looked at the habitat associations of farmland birds including on arable land.
It found that the most important field type for farmland birds over winter in terms of numbers (48%) and scale was winter stubble.
It was on this basis that the decision was made by government to scrap the winter stubble rule, according to BirdWatch Ireland.
Oonagh Duggan, head of policy and advocacy at BirdWatch Ireland said: “We welcome this decision to scrap the shallow cultivation of winter stubble rule in the Nitrates Action Programme.
"The rule was introduced in a knee-jerk reaction to address nitrate pollution where it was stated that ‘all sectors had to play their part’ but there was really inadequate consideration, ecological assessment, or mitigation of the impacts to least 30 bird species, many threatened, that forage on winter stubbles.
"The research on the risk of effects on farmland birds should have been commissioned first before any changes were proposed for winter stubbles and not after the fact.
"Nitrate pollution has to be addressed, but when trying to address one environmental problem, it makes no sense to create another one."
Duggan also stressed that though the rule has been scrapped, it will not help farmland birds this winter as farmers will have already cultivated their fields.
She said: "It was an irresponsible decision to mandate farmers to shallow cultivate without adequate consideration of the effects on declining bird species.
"We are in a biodiversity crisis and farmland birds are the fastest declining bird group in Ireland."
